OrbitaxAustralian Court Holds Australian Company Not to be Treated as "Orphan" in Determining Arm's Length Rate for Intra-Company Loan
|Approved Changes|Australia
On 21 April 2017, the full bench of the Australian Federal Court delivered its judgment to dismiss an appeal seeking to overturn a ruling from the Australian Taxation Office (ATO) that Chevron incorrectly priced an intra-company loan to shift profits offshore and avoid tax on Australian income. The case involved Chevron Australia Holdings Pty. Ltd. (Chevron Australia), which received a high-in…
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